Privacy Policy

GDPR

  1. Important Information and who we are

Purpose of this privacy notice
This privacy

notice aims to give you information on how we collect and processes your

personal data through your use of this website, including any data you

may provide through this website when you sign up to our newsletter.It

is important that you read this privacy notice together with any other

privacy notice or fair processing notice we may provide on specific

occasions when we are collecting or processing personal data about you

so that you are fully aware of how and why we are using your data. This

privacy notice supplements the other notices and is not intended to

override them. 

 

Controller – who we are
The

data controller of our site (www.procedos.com) is Procedos AB Sweden.

We have appointed a data privacy manager who is responsible for

overseeing questions in relation to this privacy notice. If you have any

questions about this privacy notice, including any requests to exercise

your legal rights, please contact info@procedos.com.You have the right

to make a complaint at any time to Datainspektionen , the Swedish

supervisory authority for data protection issues

(www.datainspektionen.se/). We would, however, appreciate the chance to

deal with your concerns before you approach Datainspektionen so please

contact us in the first instance.

 

Changes to the privacy notice and your duty to inform us of changes
This

version was last updated on 29nd March 2018. It is important that the

personal data we hold about you is accurate and current. Please keep us

informed if your personal data changes during your relationship with us.

 

Third-party links
This

website may include links to third-party websites, plug-ins and

applications. Clicking on those links or enabling those connections may

allow third parties to collect or share data about you. We do not

control these third-party websites and are not responsible for their

privacy statements. When you leave our website, we encourage you to read

the privacy notice of every website you visit.

  1. The data we collect about you

Personal data, or personal information, means any information

about an individual from which that person can be identified.We may

collect, use, store and transfer different kinds of personal data about

you which we have grouped together as follows: 

 

Identity Data 
includes first name and last name.

 

Contact Data 
includes delivery address, email address and telephone numbers.

 

Financial Data
includes bank account and payment card details.

 

Technical Data 
includes

internet protocol (IP) address browser type and version, time zone

setting and location, browser plug-in types and versions, operating

system and platform and other technology on the devices you use to

access this website.

 

Transaction Data 
includes details about payments to and from you and other details of products and services you have purchased from us.

 

Usage Data 
includes information about how you use our website, products and services.

 

Marketing and Communications Data 
includes

your preferences in receiving marketing from us and our third parties

and your communication preferences.We also collect and use Aggregated

Data such as statistical or demographic data for internal purposes.We do

not collect any Special Categories of Personal Data about you (this

includes details about your race or ethnicity, religious or

philosophical beliefs, sex life, sexual orientation, political opinions,

trade union membership, information about your health and genetic and

biometric data). Nor do we collect any information about criminal

convictions and offences.

 

If you fail to provide personal data
Where

we need to collect personal data by law, or under the terms of a

contract we have with you and you fail to provide that data when

requested, we may not be able to perform the contract we have or are

trying to enter into with you (for example, to provide you with an

answer to an enquiry). In this case, we may have to cancel a service you

have with us but we will notify you if this is the case at the time.

  1. How is your personal data collected

We use different methods to collect data from and about you including through:

 

Direct interactions. 
You

may give us your Identity Data, Contact Data, and Financial Data by

filling in forms or by corresponding with us by phone, email, post, fax,

on our website or otherwise. This includes personal data you provide

when you:

  • purchase our products;
  • register a user account on our website;
  • submit an enquiry;
  • enter a competition, promotion or survey; or
  • request our newsletter to be sent to you.

Automated technologies or interactions.
As you

interact with our website, we may automatically collect Technical Data

about your equipment, browsing actions and patterns. We collect this

personal data by using cookies, and other similar technologies.

  1. How we use your personal data

We will only use your personal data when the law allows us to.

Most commonly, we will use your personal data in the following

circumstances:

  • where we need to perform the contract we are about to enter into or have entered into with you;
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
  • where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for

processing your personal data other than in relation to sending third

party direct marketing communications to you via email or text message.

You have the right to withdraw consent to marketing at any time by

contacting us.

 

Purposes for which we will use your personal data
We

have set out below, in a table format, a description of all the ways we

plan to use your personal data, and which of the legal bases we rely on

to do so. We have also identified what our legitimate interests are

where appropriate.Note that we may process your personal data for more

than one lawful ground depending on the specific purpose for which we

are using your data. Please contact us if you need details about the

specific legal ground we are relying on to process your personal data

where more than one ground has been set out in the table below.

 

Purpose / ActivityType of DataLawful basis for processing including basis of legitimate interest 

To process and deliver your order including managing payments.

 

(a) Identity
(b) Contact
(c) Financial
(d) Marketing and Communications
(e) Transaction(a) Performance of a contract with you.
(b) Necessary for our legitimate interests. To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey(a) Identity
(b) Contact
(c) Marketing and Communications(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c)

Necessary for our legitimate interests (to keep our records updated and

to study how customers use our products/services) To enable you to

partake in a prize draw, competition or complete a survey(a) Identity
(b) Contact
(c) Usage
(d) Marketing and Communications(a) Performance of a contract with you
(b)

Necessary for our legitimate interests (to study how customers use our

products/services, to develop them and grow our business) To respond to

your enquiry submitted on the site, or via phone, email, post or

otherwise.(a) Identity
(b) Contact(a) Performance of a contract with you.
(b)

Necessary for our legitimate interests (where you have made contact

with us prior to entering into a contractual relationship with us.) To

administer and protect our business and this website (including

troubleshooting, data analysis, testing, system maintenance, support,

reporting and hosting of data).(a) Identity
(b) Contact
(c)

Technical(a) Necessary for our legitimate interests (for running

ourbusiness, provision of administration and IT services, network

security, to prevent fraud and in the context of a business

reorganisation or group restructuring exercise).
(b)

Necessary to comply with a legal obligation. To use data analytics to

improve our website, products/services, marketing, customer

relationships and experiences.(a) Technical
(b)

Marketing and CommunicationsNecessary for our legitimate interests (to

define types of customers for our products and services, to keep our

website updated and relevant, to develop our business and to inform our

marketing strategy). To make suggestions and recommendations to you

about services that may be of interest to you.(a) Identity
(c) Technical
(d)

Marketing and CommunicationsNecessary for our legitimate interests (to

develop our products/services and grow our business) which, if you are

an individual, will include reliance on the soft opt-in principle (in

accordance with Regulation 22 of The Privacy & Electronic

Communications (EC Directive) Regulations 2003).

 

Marketing
We

strive to provide you with choices regarding certain personal data

uses, particularly around marketing and advertising. We may use your

Identity, Contact, Technical and Marketing or Communications Data to

form a view on what we think you may want or need, or what may be of

interest to you. This is how we decide which services and offers may be

relevant for you (we call this marketing).You will receive marketing

communications from us if you have requested information from us and

unless you have opted out of receiving that marketing. You can ask us or

third parties to stop sending you marketing messages at any time by

contacting us at any time.

 

Cookies
Our

website uses so called session cookies. Session cookies are not saved

permanently on your computer. They are erased the minute you close your

web browser. By changing the settings in your browser you can choose not

to accept cookies. However, there is a risk that our web shop

facilities will not work properly. These cookie settings are changed in

various ways, depending on which kind of browser you use. For further

instructions, please consult the “Help” section for you particular

browser.

 

Change of Purpose
We

will only use your personal data for the purposes for which we

collected it, unless we reasonably consider that we need to use it for

another reason and that reason is compatible with the original purpose.

If you wish to get an explanation as to how the processing for the new

purpose is compatible with the original purpose, please contact us.

  1. Disclosures of your personal data

We may have to share your personal data with the parties set out

below for the purposes set out in the table in paragraph 4 above:

  • External Third Parties as set out in the Glossary
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your

personal data and to treat it in accordance with the law. We do not

allow our third-party service providers to use your personal data for

their own purposes and only permit them to process your personal data

for specified purposes and in accordance with our instructions.

 

  1. International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

 

  1. Data Security

We have put in place appropriate security measures to prevent your

personal data from being accidentally lost, used or accessed in an

unauthorised way, altered or disclosed. In addition, we limit access to

your personal data to those employees, agents, contractors and other

third parties who have a business need to know. They will only process

your personal data on our instructions and they are subject to a duty of

confidentiality. We have put in place procedures to deal with any

suspected personal data breach and will notify you and any applicable

regulator of a breach where we are legally required to do so.

 

  1. Data Retention

We will only retain your personal data for as long as necessary to

fulfill the purposes we collected it for, including for the purposes of

satisfying any legal, accounting, or reporting requirements.To

determine the appropriate retention period for personal data, we

consider the amount, nature, and sensitivity of the personal data, the

potential risk of harm from unauthorised use or disclosure of your

personal data, the purposes for which we process your personal data and

whether we can achieve those purposes through other means, and the

applicable legal requirements.Details of retention periods for different

aspects of your personal data are available in our retention policy

which you can request from us by contacting us.

 

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please

contact us.You will not have to pay a fee to access your personal data

(or to exercise any of the other rights). However, we may charge a

reasonable fee if your request is clearly unfounded, repetitive or

excessive. Alternatively, we may refuse to comply with your request in

these circumstances.

 

What we may need from you
We

may need to request specific information from you to help us confirm

your identity and ensure your right to access your personal data (or to

exercise any of your other rights). This is a security measure to ensure

that personal data is not disclosed to any person who has no right to

receive it. We may also contact you to ask you for further information

in relation to your request to speed up our response.We try to respond

to all legitimate requests within one month. Occasionally it may take us

longer than a month if your request is particularly complex or you have

made a number of requests. In this case, we will notify you and keep

you updated.

 

  1. Glossary

LAWFUL BASIS
Legitimate Interest 
means

the interest of our business in conducting and managing our business to

enable us to give you the best service/product and the best and most

secure experience. We make sure we consider and balance any potential

impact on you (both positive and negative) and your rights before we

process your personal data for our legitimate interests. We do not use

your personal data for activities where our interests are overridden by

the impact on you (unless we have your consent or are otherwise required

or permitted to by law). You can obtain further information about how

we assess our legitimate interests against any potential impact on you

in respect of specific activities by contacting us.

 

Request access 
to

your personal data (commonly known as a "data subject access request").

This enables you to receive a copy of the personal data we hold about

you and to check that we are lawfully processing it.

 

Request correction 
of

the personal data that we hold about you. This enables you to have any

incomplete or inaccurate data we hold about you corrected, though we may

need to verify the accuracy of the new data you provide to us.

 

Request erasure 
of

your personal data. This enables you to ask us to delete or remove

personal data where there is no good reason for us continuing to process

it. You also have the right to ask us to delete or remove your personal

data where you have successfully exercised your right to object to

processing (see below), where we may have processed your information

unlawfully or where we are required to erase your personal data to

comply with local law. Note, however, that we may not always be able to

comply with your request of erasure for specific legal reasons which

will be notified to you, if applicable, at the time of your request.

 

Object to processing 
of

your personal data where we are relying on a legitimate interest (or

those of a third party) and there is something about your particular

situation which makes you want to object to processing on this ground as

you feel it impacts on your fundamental rights and freedoms. You also

have the right to object where we are processing your personal data for

direct marketing purposes. In some cases, we may demonstrate that we

have compelling legitimate grounds to process your information which

override your rights and freedoms.

 

Request restriction of processing 
of

your personal data. This enables you to ask us to suspend the

processing of your personal data in the following scenarios: (a) if you

want us to establish the data's accuracy; (b) where our use of the data

is unlawful but you do not want us to erase it; (c) where you need us to

hold the data even if we no longer require it as you need it to

establish, exercise or defend legal claims; or (d) you have objected to

our use of your data but we need to verify whether we have overriding

legitimate grounds to use it.

 

Request the transfer 
of

your personal data to you or to a third party. We will provide to you,

or a third party you have chosen, your personal data in a structured,

commonly used, machine-readable format. Note that this right only

applies to automated information which you initially provided consent

for us to use or where we used the information to perform a contract

with you.

 

Withdraw consent at any time 
where

we are relying on consent to process your personal data. However, this

will not affect the lawfulness of any processing carried out before you

withdraw your consent. If you withdraw your consent, we may not be able

to provide certain products or services to you. We will advise you if

this is the case at the time you withdraw your consent.